SecProbe.io

January 27, 2011
 Eric A. Rose, M.D. Chief Executive Officer SIGA Technologies, Inc. 35 East 62
nd Street
New York, NY 10065

Re: SIGA Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 10, 2010 File No. 000-23047

Dear Dr. Rose:
 We have reviewed your supplemental response filed December 20, 2010 and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Definitive Proxy Statement on Schedule 14A

 Annual Incentive Compensation, page 17

1. We note your response to our prior comment 1.  However, your disclosure is still too
general.  Please expand your draft disclosure further to identify:

• the specific performance objectives th e Compensation Committee considered in
making the $75,000 discretionary award to Dr. Hruby; and

• the degree to which these objectives were  satisfied, quantified where possible.

As just one example, when you refer to th e “new grants and other third-party funding
obtained,” it is unclear what the precise objec tive was to begin with, the precise nature of
the new grants and funding you are referring to, and how the actual amount of funding
received compares to the obj ectives that were establishe d for Mr. Hruby.  Without this

Eric A. Rose, M.D. SIGA Technologies, Inc.  January 27, 2011 Page 2

information, shareholders and investors may be unable to adequately assess whether Mr.
Hruby was properly incentivized or determ ine how well the company is applying the
“pay for performance” model.
 Long-Term Incentive Awards, page 17

2. We note your response to our prior comment  2.  As with our comment above, please
expand your draft disclosu re further to include:

• the specific performance objectives th e Compensation Committee considered in
making the stock option awards to  Ms. Dugary and Dr. Hruby; and

• the degree to which these objectives were  satisfied, quantified where possible.

For example, your reference to “Ms. Dugary’s  role in achieving the Company’s financial
goals, her relationships with shareholders and potential investors, [and] her efforts with
respect to financial regulatory compliance, ” is unnecessarily va gue.  Investors and
shareholders need to understand what th e Company’s financial goals were and Mr.
Dugary’s role in achieving those goals, what  you mean by “relationships with potential
investors” and what Ms. Dugary’s effort s were, specifically, with respect to the
company’s regulatory compliance.  In addition to  these specifics, it is important that you
disclose how Ms. Dugary’s achievement of these things compared to the Committee’s
expectations for her.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Eric A. Rose, M.D. SIGA Technologies, Inc.  January 27, 2011 Page 3

You may contact Michael Ro senthall, Staff Attorney, at (202) 551-3674 or Daniel
Greenspan, Special Counsel, at (202) 551-3623 with any questions.

Sincerely,    Jeffrey P. Riedler Assistant Director